By Amanda Durish Cook

CARMEL, Ind. — MISO officials last week said they agree with almost all the recommendations outlined by the Independent Market Monitor in this year’s State of the Market report.

However, RTO staff will need to perform further analysis before committing to solutions for three of the six recommendations, officials said.

Monitor David Patton produced six new recommendations in June as part of his 2018 report, among them clarifying the criteria for calling emergencies, procuring operating reserves on the Midwest-to South regional transfer limit and lowering the generator shift factor (GSF) cutoff for transmission constraints with limited relief. (See MISO Monitor Poses 6 New Market Recommendations.)

“After talking and interacting over the summer, we agree with most problem statements,” MISO Executive Director of Market Strategy and Design Scott Wright told stakeholders during Thursday’s Market Subcommittee meeting, where he presented the RTO’s official response to the Monitor’s report. MISO’s Tariff requires it to provide a formal response to the Monitor’s recommendations within 120 days.

Wright said a decision to procure operating reserves on the regional dispatch transfer limit doesn’t come down to MISO alone: The RTO must approach the joint parties to the transmission use agreement to discuss their willingness to create reserves.

“We just can’t say, ‘We’re going to do that,’” Wright said.

MISO also must proceed carefully and conduct more analysis if it’s to create lower GSF cutoffs for transmission constraints with limited relief, he said. “We think we need to think more about the solution.”

The Monitor’s report had also criticized MISO’s default emergency price floors as being unreasonable. “The default floors are set by a supplier’s offer, which has resulted in them often being inefficiently low and can result in them being inefficiently high,” it said.

MISO said it agreed with the Monitor on that item and would work on emergency and scarcity pricing improvements in 2020. It also agreed that it should clear up the criteria and improve the logging for declaring emergencies and taking emergency actions.

MISO in Sync with RA Recommendations

Director of Resource Adequacy Coordination Matt Ellis said MISO agreed with the Monitor’s two recommendations related to resource adequacy and that both are being covered in ongoing discussions over the RTO’s resource availability and need projects.

The Monitor had asked for MISO’s planning assumptions to include a more realistic volume of unforced outages and derates during peak-load conditions. It also wants the RTO to account for capacity resources’ behind-the-meter process load and devise a method for validating suppliers’ submitted data. MISO’s current capacity accreditation rules only account for forced outage rates.

Ellis said that while MISO agrees with both recommendations, accounting for unforced and unreported outages and derates in capacity accreditation will require more evaluation.

One Recommendation down

MISO said that by the beginning of next year, it will address one of the Monitor’s previous criticisms that capacity auctions allow for participation by resources that plan to be on outage for the entire planning year. The RTO last month filed a provisional solution that disqualifies capacity resources from auction participation if they plan to be unavailable for 90 of the first 120 days of the planning year. It expects a MISO Eases New Rules on Extended Outages.)